SOX...Signing vs. Initialing 3012

  • Can someone provide specific guidance on what is acceptable/preferred’ signing or initialing from a SOX perspective?
    I would think a signature would be best but we have a few documents that were initialed rather than signed and I am trying to determine the best course of action.
    Any help would be great…thanks.

  • Can you be more specific as to what type of documents you are referencing? Are the initials evidencing review or are they on a SEC filing?
    SOX rules and even guidelines will not have any specific information as to what is preferred if you are just referring to evidence of review.

  • Thanks for the quick response.
    These are not SEC filing docs. The documents I am referring to are internal approval documents. For example, managements approval of purchasing land or authorization for expenditure (AFE).
    However, these processes are specific SOX key controls.

  • There won’t be any rules governing this type of approval. You are free to set your own internal guidelines.

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